Patent Owner’s Opposition
`Case No. 2014-00003
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`
`
`AKER BIOMARINE AS and ENZYMOTEC LTD.
`Petitioners
`
`v.
`
`NEPTUNE TECHNOLOGIES AND BIORESSOURCES INC.
`Patent Owner
`
`______________________
`
`CASE IPR2014-000031
`U.S. Patent No. 8,278,351 B2
`______________________
`
`PATENT OWNER’S OPPOSITION TO PETITIONER
`AKBM’S MOTION FOR ADDITIONAL DISCOVERY
`
`
`
`
`1 Case IPR2014-00556 has been joined with this proceeding.
`
`
`Case No. 2014-00003
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`
`
`AKER BIOMARINE AS and ENZYMOTEC LTD.
`Petitioners
`
`v.
`
`NEPTUNE TECHNOLOGIES AND BIORESSOURCES INC.
`Patent Owner
`
`______________________
`
`CASE IPR2014-000031
`U.S. Patent No. 8,278,351 B2
`______________________
`
`PATENT OWNER’S OPPOSITION TO PETITIONER
`AKBM’S MOTION FOR ADDITIONAL DISCOVERY
`
`
`
`
`1 Case IPR2014-00556 has been joined with this proceeding.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`Aker’s expansive requests are not routine discovery and are not favored by the
`
`interests of justice. The requested materials are not relevant, let alone useful, and Aker
`
`could present analogous information through other means. In fact, Aker itself characterizes
`
`the requested discovery as cumulative of a “wealth” of allegedly similar evidence already of
`
`record. (E.g., Mot. at 8-10.)
`
`Unable to satisfy the requirements for routine or additional discovery under 37 C.F.R.
`
`42.51(b), Aker resorts to casting unfounded aspersions at Neptune and injecting arguments
`
`about the merits issues in these proceedings. The requested documents must be relevant,
`
`Aker insists, because Neptune did not agree to produce them. This notion is baseless and
`
`hypocritical. Neptune did not agree to Aker’s requests because they seek irrelevant and
`
`highly confidential materials, previously produced only pursuant to a stringent ITC protective
`
`order. There is nothing nefarious about Neptune’s desire to protect its proprietary
`
`information. Indeed, Aker itself refused to produce its confidential ITC documents because
`
`it did not want to “waive” the protections of the ITC’s order.
`
`Neptune should not be forced to put a thousand-plus pages of highly sensitive and
`
`irrelevant information into the hands of its competitors’ prosecuting attorneys and,
`
`potentially, the public domain. The Board should deny Aker’s Motion. In addition, the Board
`
`should expunge the portions of Aker’s Motion that are, as detailed below, unauthorized
`
`arguments on the merits and wholly unrelated to Aker’s discovery requests, which Aker
`
`included in an effort to circumvent the page limits for Petitioners’ Reply.
`
`
`
`1.
`
`
`
`I.
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`THE REQUESTED DISCOVERY IS HIGHLY CONFIDENTIAL AND SUBJECT TO
`AN ITC PROTECTIVE ORDER
`The materials Aker requests are confidential documents Neptune produced in prior
`
`litigation between the parties before the U.S. International Trade Commission (“ITC”).
`
`Neptune, without challenge from Aker, designated all of the requested documents as
`
`“Confidential Business Information” (CBI) pursuant to the ITC Protective Order. All parties
`
`are bound under the ITC protective order to use CBI solely for purposes of the ITC
`
`Investigation, which is now terminated.
`
`Neptune attempted to reach a mutual agreement with Petitioners to use certain CBI
`
`documents in this proceeding, but Petitioners refused to enter into such an agreement.
`
`Petitioners would not even negotiate the issue in good faith. Accordingly, during the May
`
`28, 2014 conference call with the Board, Neptune proposed a procedure for requesting
`
`and/or objecting to the use of CBI documents. See NEPN Ex. 2027, 31:12-36:2. Aker
`
`opposed Neptune’s request and argued that use of Aker CBI documents would mean
`
`“waiving our [Aker’s] confidentiality concerns.” Id. at 36:22-37:1. Aker’s counsel further
`
`stressed that any agreement to use CBI documents “needs to be reciprocal and the
`
`parties still need to agree on that.” Id. at 36:13-17 (emphasis added).
`
`A reciprocal agreement was never reached. As a result, Neptune was barred from
`
`using Petitioners’ relevant CBI documents in depositions and in its Patent Owner Response.
`
`
`
`2.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`Now speaking out of the other side of its mouth, Aker urges the Board to ignore
`
`Neptune’s confidentiality interests and order a voluminous, indiscriminate production of
`
`Neptune CBI. Aker’s arguments ring hollow in light of its refusal to produce its CBI absent a
`
`“reciprocal” agreement. The documents Aker requests are also far more sensitive than the
`
`small number of documents Neptune requested from Aker. The requested Neptune
`
`documents disclose, for example, details regarding Neptune’s commercial manufacturing
`
`processes, business plans, and proprietary research and development activities.
`
`While Neptune agreed to a separate protective order for this IPR, the IPR protective
`
`order was drafted to cover the limited scope of discovery available in IPR, not the broad
`
`discovery available in the ITC. See Garmin Int’l, Inc. v. Cuozzo Speed Techs. LLC, Case
`
`No. IPR2012-00001, Paper No. 26 at 5 (P.T.A.B. Mar. 5, 2013) (“in inter partes review,
`
`discovery is limited as compared to that available in district court litigation.”). Given the
`
`limited scope of discovery, IPR protective orders are logically more limited than protective
`
`orders that the ITC or district courts may issue. For example, Neptune’s understanding is
`
`that the Board must retain the right to declassify confidential information, and that
`
`prosecution bars are not permitted. See U.S.P.T.O. Trial Practice Guide, App’x B; CRS
`
`Adv. Techns., Inc. v. Frontline Techs., Inc., Case No. CBM2012-00005, Paper 43 at 3
`
`(P.T.A.B. May 28, 2013) (“A protective order that deviates from the Board’s default
`
`protective order must nonetheless include [mandatory] terms as outlined in the Office
`
`Practice Guide”).
`
`
`
`3.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`Accordingly, the parties agreed that this IPR protective order would cover CBI
`
`documents only by mutual agreement. NEPN Ex. 2033. ¶ 6. Aker itself argued that
`
`producing CBI under an IPR protective order would “waiv[e]” the protections ordered by the
`
`ITC. This does not mean this IPR protective order is “deficient,” as Aker claims, but simply
`
`that it does not and cannot sufficiently cover the Neptune CBI Aker demands. The problem
`
`is not with the IPR protective order, but with Aker’s requests for highly confidential
`
`information that is, as detailed below, wholly irrelevant to this proceeding.
`
`II.
`
`
`
`AKER’S REQUESTS ARE NOT ROUTINE DISCOVERY
`
`Aker’s requests do not call for routine discovery. “Routine discovery under 37 C.F.R.
`
`§ 41.51(b)(1)(iii) is narrowly directed to specific information known to the responding party to
`
`be inconsistent with a position advanced by that party in the proceeding, and not broadly
`
`directed to any subject area in general within which the requesting party hopes to discover
`
`such inconsistent information.” Garmin at 4. Neptune has produced all information covered
`
`by routine discovery, and knows of no information in its possession that is inconsistent with
`
`positions it has advanced in this proceeding.
`
`III.
`
`AKER’S REQUESTS FAIL THE GARMIN TEST FOR ADDITIONAL DISCOVERY
`
`To obtain something more than routine discovery, Aker must prove that its requests
`
`meet the demanding five-factor “interest of justice” test set forth in Garmin. Aker fails to
`
`meet this burden. Its requests fail under at least Garmin factors 1 and 3 because the
`
`
`
`4.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`information they seek to elicit is not useful, and because equivalent information is available
`
`through other means that do not risk compromising Neptune CBI.
`
`A. CaPre email (RX-0456C)
`
`
`
`This 2010 internal email purports to summarize heat treatments (all well below
`
`125°C) performed on CaPre®, a product manufactured by a Neptune subsidiary. Aker
`
`argues that RX-0456C relates to whether or not hydrolysis will occur when Beaudoin’s oil is
`
`heated to 125°C for 15 minutes per the required Beaudoin heating step.
`
`
`
`Testing of a finished commercial product manufactured nearly a decade after the
`
`‘351 Patent priority date is not relevant, let alone “useful,” to determining how a crude krill oil
`
`extract made in accordance with Beaudoin would degrade as a result of Beaudoin’s heating
`
`step. Aker would have the Board believe that any krill oil responds to heating in the same
`
`way, despite the record evidence to the contrary. It is undisputed that an oil’s susceptibility
`
`to hydrolysis is influenced by water and free fatty acid content.2 The water content and
`
`other relevant characteristics of a refined commercial oil like CaPre® are not analogous to
`
`Beaudoin’s crude krill oil fractions. This request therefore fails under Garmin factor 1.
`
`
`2 See, e.g., NEPN Ex. 2060, p. 6 (showing the “smoke point” of soybean oil). Neptune has
`
`not, as Aker claims, equated soybean oil with Beaudoin krill oil; Neptune has cited the
`
`smoke point diagram to illustrate the general principle that an oil’s free fatty acid content will
`
`affect the temperature at which hydrolysis occurs. NEPN Ex. 2059, Jaczynski Decl., ¶ 18.
`
`
`
`5.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`Even if testing on a commercial product could be useful, Aker’s request still fails
`
`
`
`under Garmin factor 3 because Aker has or could have obtained data of this nature through
`
`other means. CaPre® is no more similar to Beaudoin oil than Aker’s own krill oil products.
`
`If Aker wants to rely on this type of data, it should submit analyses on its own products, or
`
`on the numerous “recreation” Beaudoin oil samples it has commissioned.
`
`B. Transcripts from ITC Depositions of Dr. Fotini Sampalis (Vols. I-III)
`
`
`
`These transcripts comprise three full days of testimony given by Dr. Sampalis as a
`
`fact witness, and specifically, as a Federal Rule of Civil Procedure 30(b)(6) corporate
`
`representative on dozens of topics that are undisputedly irrelevant here. The nearly 900
`
`pages of testimony are replete with Neptune CBI. For example, in response to topics
`
`related to the existence of a “domestic industry” under 19 U.S.C. § 1337, a disputed issue in
`
`the ITC litigation, Dr. Sampalis testified about Neptune’s sales, distribution chain, and
`
`business plans. Dr. Sampalis also testified in extensive detail about Neptune’s proprietary
`
`manufacturing processes and research and development activities.
`
`
`
`There is no apparent reason why “the subjective mindset or opinions” of the inventor
`
`would be useful here. See Intri-Plex Techs. v. Saint-Gobain Performance Plastics Rencol
`
`Ltd., Case No. IPR2014-00309, Paper No. 40 at 12 (P.T.A.B. Sept. 4, 2014); see also Apple
`
`Inc. v. Achates Reference Publ’g, Inc., Case No. IPR-2013-00080/81, Paper 28 at 3
`
`(P.T.A.B. July 2, 2013) (denying leave to file motion seeking production of inventor
`
`deposition testimony from related litigation). Aker claims that Dr. Sampalis gave testimony
`
`
`
`6.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`relevant to Beaudoin’s heating step, but that testimony was actually about Neptune
`
`commercial manufacturing processes, and so is not relevant or useful for the reasons
`
`detailed in Section III(A) above. To the extent Dr. Sampalis gave any testimony about the
`
`Beaudoin patent, Aker suggests no reason why such testimony would be useful or beyond
`
`what any one of Aker’s team of experts could provide.
`
`C. Report on NKO® (RX-0398C)
`
`
`
`Contrary to Aker’s assertion, this study of Neptune’s NKO® product does not relate
`
`to, let alone “undermine,” Neptune’s proposed construction of the term “about 5%,” which
`
`appears in claims 5 and 28. Claim construction is a question of law on which this
`
`confidential study, created six years after the ‘351 Patent priority date, has no bearing.
`
`Furthermore, while NKO® embodies certain inventions of the ‘351 Patent, Neptune has not
`
`contended that NKO® practices claim 5 or 28.
`
`
`
`This request also fails under Garmin factor 3. If Aker wants to submit testing of
`
`NKO®, it can buy the product and run its own analyses; it does not need discovery of
`
`Neptune’s confidential records.
`
`D. Transcript and Exhibits 4 and 5 from ITC Deposition of Pierre St-Jean
`These documents are not relevant to Neptune’s criticisms of Petitioners’ alleged
`
`
`
`Beaudoin repeats. These documents relate to a failed attempt by Mr. St-Jean, a Neptune
`
`employee, to repeat the Beaudoin patent in 2009. In his 2009 experiment, Mr. St-Jean
`
`deviated from his superiors’ instructions and, by his own admission, did not faithfully repeat
`
`
`
`7.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`the Beaudoin method. Accordingly, Neptune did not submit the 2009 experiment to the
`
`Patent Office because it is irrelevant to how a person of ordinary skill in the art would
`
`faithfully repeat the Beaudoin patent.3
`
`IV.
`
`
`AKER’S UNAUTHORIZED MERITS ARGUMENTS SHOULD BE EXPUNGED
`Aker has improperly utilized its Motion as a vehicle for merits arguments unrelated to
`
`its discovery requests. (See, e.g., Mot. at 3-10.) The Board authorized Aker to file a
`
`“motion requesting additional discovery,” not general briefing on the disputed issues in this
`
`proceeding. Paper 79 at 3 (Sept. 3, 2014).
`
`
`
`The Board should expunge the unauthorized portions of Aker’s brief pursuant to 37
`
`C.F.R. § 42.7(a). See Illumina, Inc. v. Trustees of Columbia Univ., Case No. IPR2012-
`
`00006, Paper 34 (P.T.A.B. Apr. 18, 2013) (expunging Petitioner’s filing because it contained
`
`improper argument and evidence). Aker’s extraneous merits briefing is a clear attempt to
`
`circumvent the page limits for Petitioners’ Reply. Giving Aker additional opportunity for
`
`
`3 Mr. St-Jean offered no expert opinions in the ITC case, and his deposition testimony
`
`indicates that he was not one of skill in the art in 2001 under either side’s proposed
`
`definition.
`
`
`
`8.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`merits argument would prejudice Neptune, particularly since Neptune has already submitted
`
`its Patent Owner Response and thus cannot respond to Aker’s new arguments.4
`
`
`
`Accordingly, the Board should expunge the following portions of Aker’s brief and the
`
`associated exhibits: section I(a); section I(c); and AKBM Exhibits 1093, 1094, 1098-1100,
`
`1102-1103. Examples of Aker’s improper arguments contained in these portions are set
`
`forth below.
`
` “It is undisputed that the claimed krill extracts need contain only one
`
`molecule of the Claimed Phospholipid in order to anticipate the independent
`
`claims at issue” (Mot. § I(a), p. 3; see also p. 4)
`
`
`
`This argument is unrelated to Aker’s discovery requests and is also incorrect. The
`
`independent claims at issue require other elements besides Claimed Phospholipid,5 for
`
`
`4 While the Board permitted Neptune additional pages for this Opposition in order to
`
`address the improper portions of Aker’s Motion, these additional pages are not sufficient to
`
`substantively address the broad scope of merits issues Aker raises. In addition, Neptune
`
`has no opportunity to submit evidence, including expert testimony, in response to Aker’s
`
`new arguments. Failure to expunge these unauthorized merits arguments from Aker’s brief
`
`would therefore prejudice Neptune.
`
`5 Neptune uses the term “Claimed Phospholipid” as defined at page 3 of Aker’s Motion to
`
`refer to the specific phospholipids recited in the ‘351 Patent claims.
`
`
`
`9.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`example, that the extract be “suitable for human consumption.” AKBM Ex. 1001 (claims 1
`
`and 24). Nor is it “undisputed” that a single molecule of Claimed Phospholipid is necessarily
`
`sufficient to satisfy the Claimed Phospholipid limitation. For example, as Neptune has
`
`argued, if an extract does not have detectable amounts of Claimed Phospholipid, one
`
`cannot conclude that the Claimed Phospholipid is present. See Neptune Patent Owner
`
`Response, Paper 66, pp. 29-30 (July 1, 2014). In other words, Aker cannot satisfy its
`
`burden of proof by arguing that an extract could hypothetically contain elements that were
`
`not detected.
`
` “There is only one place in the ‘351 Patent specification that purports to teach
`
`how to make the allegedly inventive extracts … using words [ ] similar to
`
`those of Beaudoin I” (Mot. § I(c)(1), p. 5)
`
`In this section, Aker rehashes its argument that the process disclosed in the ‘351
`
`Patent is “similar” to the process disclosed by Beaudoin, and further argues that there “is
`
`only one place” in the ‘351 specification that discloses how to practice the invention. (Mot.
`
`at 4.) Aker does not even attempt to connect these arguments to its discovery requests.
`
`Moreover, these arguments misapprehend the ‘351 Patent and its teachings. The
`
`‘351 Patent does not state that “Beaudoin I’s methods could be used to produce its claimed
`
`extracts.” (See Mot. at 5.) The ‘351 specification clearly distinguishes itself from Beaudoin,
`
`for example, by its focus on recovery of intact phospholipids, an idea Beaudoin does not
`
`teach or suggest. To preserve intact phospholipids, the ‘351 Patent teaches the avoidance
`
`
`
`10.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`of excessive heat and specifically, avoidance of the heating step required by Beaudoin’s
`
`method. The examiner agreed the ‘351 claims were novel over Beaudoin I.6
`
` “Dr. Jaczynski admitted … that following Beaudoin’s procedure, the Claimed
`
`Phospholipid is present before and after the alleged heating step”
`
`(Mot. § I(c)(1), p. 7 and associated AKBM Exs. 1093 and 1094)
`
`
`
`This argument is misleading and unrelated to Aker’s discovery requests. In the cited
`
`portion of Dr. Jaczynski’s deposition testimony, which is from the parties’ prior ITC litigation,
`
`Dr. Jaczynski states he was not opining that Beaudoin’s heating step would necessarily
`
`destroy every last molecule of Claimed Phospholipid. (See Mot. at 7.) This is not an
`
`admission that a single molecule, or detectable amounts, of Claimed Phospholipid would
`
`always be present after the heating step. Indeed, Aker’s alleged recreations prove that
`
`following the heating step, Claimed Phospholipid is not necessarily present in detectable
`
`amounts. See Neptune Patent Owner Response, Paper 66, pp. 29-30 (July 1, 2014).
`
` “the only experiments Neptune has conducted confirm Beaudoin I anticipates”
`
`(Mot. § I(c)(3), p. 8, and associated AKBM Exs. 1098-1100, 1102-1103)
`
`
`6 The ‘351 specification also teaches how to practice the invention in many places other
`
`than the few lines Aker cites. See, e.g., Neptune Patent Owner Response, Paper 66, pp.
`
`12, 14 (July 1, 2014).
`
`
`
`11.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`Aker puts forth extensive argument, and thousands of pages of new exhibits,
`
`
`
`regarding prior Beaudoin recreations attempted by Neptune. These prior Neptune
`
`experiments are irrelevant to Aker’s discovery requests.
`
`
`
`As Aker knows full well, the 2009 Neptune experiment Aker cites was a failed
`
`attempt to recreate Beaudoin. In the prior ITC litigation, Neptune produced unchallenged
`
`evidence that the 2009 Beaudoin experiment conducted by Pierre St-Jean failed to faithfully
`
`repeat the prior art process and so was irrelevant to anticipation. See infra section III(D).
`
`Aker’s accusation that Neptune “hid” this experiment from the PTO (Mot. at 10) is as
`
`baseless as it is irrelevant to Aker’s motion for additional discovery.
`
`V.
`
`CONCLUSION
`For the foregoing reasons, Aker’s motion should be denied, and the Board should
`
`expunge the following portions of Aker’s motion and the associated exhibits: section I(a);
`
`section I(c); and AKBM Exhibits 1093, 1094, 1098-1100, 1102-1103.
`
`Respectfully submitted,
`COOLEY LLP
`
`/J. Dean Farmer /
`J. Dean Farmer, Ph.D.
`Reg. No. 57,917
`
`
`
`
`
`
`By:
`
`
`
`Dated: September 16, 2014
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue, N.W.
`Suite 700
`Washington, DC 20004-2400
`
`Tel: (617) 937-2371
`Fax: (202) 842-7899
`
`
`
`
`
`
`12.
`
`
`
`Patent Owner’s Opposition
`Case No. 2014-00003
`
`
`CERTIFICATION OF SERVICE UNDER 37 C.F.R. §§ 42.6(e), 42.205(b)
`I, J. Dean Farmer, Ph.D., hereby certify that the foregoing PATENT OWNER’S
`
`OPPOSITION TO PETITIONER AKBM’S MOTION FOR ADDITIONAL DISCOVERY was
`served electronically (as consented to by Petitioners) on September 16, 2014, the same day
`as the filing of the above-identified document in the United States Patent and Trademark
`Office (USPTO), upon:
`
`Amanda Hollis
`amanda.hollis@kirkland.com
`Hand delivery address:
`KIRKLAND & ELLIS
`300 North LaSalle
`Chicago, IL 60654
`Telephone: 312-862-2011
`Facsimile: 312-862-2200
`Reg. No. 55,629
`
`
`
`J. Mitchell Jones
`jmjones@casimirjones.com
`docketing@casimirjones.com
`Hand delivery address:
`CASIMIR JONES SC
`2275 Deming Way, St. 310
`Middleton, WI 53562
`Telephone: (608) 662-1277
`Facsimile: (608) 662-1276
`Reg. No. 44,174
`
`Dated: September 16, 2014
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Avenue, N.W.
`Suite 700
`Washington, DC 20004-2400
`Tel: (617) 937-2371
`Fax: (202) 842-7899
`
`
`
`110160336
`
`
`
`Elizabeth J. Holland
`eholland@goodwinprocter.com
`Goodwin Procter LLP
`The New York Times Building
`620 Eighth Avenue
`New York, NY 10018
`Telephone: (212) 813-8800
`Facsimile: (212) 355-3333
`Reg. No. 47,657
`
`Cynthia Lambert Hardman
`chardman@goodwinprocter.com
`Goodwin Procter LLP
`The New York Times Building
`620 Eighth Avenue
`New York, NY 10018
`Telephone: (212) 813-8800
`Facsimile: (212) 355-3333
`Reg. No. 53,179
`
`
`
`Respectfully submitted,
`
`COOLEY LLP
`
`/J. Dean Farmer/
`J. Dean Farmer, Ph.D.
`Reg. No. 57,917
`
`
`
`By:
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